ML20151T933

Ack Receipt of Util 880625 & 0707 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/88-16 & Mgt Meeting Rept 50-293/88-26 on 880627

ML20151T933
Person / Time
Site:	Pilgrim
Issue date:	08/09/1988
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
References
NUDOCS 8808180335
Download: ML20151T933 (2)

See also: IR 05000293/1988016

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.AUGM91988  ;

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Docket No. 50-293

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$ Boston Edison Company

ATTN: Mr. Ralph G. Bird i

Sonir.e Vice President - Nuclear '

800 Boylston Street

Boston, Ma w.husetts 0?l99. ,

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Gentlemen:

Subject: Inspection No. 50-293/88 .17 and .*ianagement Meeting 50-293/88-26'

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Tnis refers to your letter dated June 25, 1988, in response to our letter

dated May 25, 1988 concerning inspection 50-293/83-17; and to your letter

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dated July 7, 1988 which was in response to additional concerns raised at our  :

Management P.eeting 50-293/88-26 condiacted. on Juna 27, 1988 and in a subsequent  !

phone conversation between Mr. Galla of this office end Mr. K. Highfi D of -your

staff on July 1,1983.

Thank you for informing us of the corrective ~and provar;tive actiona documeritd

in your letters. These actions will be examined during a future inspect!_on of

ycur licensed program. .

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Your cooneration with us is appreciated. 1

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Sincerely, I

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! ORl0lNAL SIGNED SY

) WILLIAM V. JOHNSTON i

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i William V. Johnston, Act %g Director i

Division of Reactor Safety l

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! 0FFICIAL RECORD COPY RL PILGRIM 88-17 - 0001.0.0'

08/04/88

8808180335 880809 r,[Oj

PDR ADOCK 05000293 j \\

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. Boston Edison Company 2 .

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K. Highfill, Station Director  !

i R. Anderson, Plant Manager  !

J. Keyes, Licensing Division Manager 1

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E. Robinson, Nuclear Information Manager.

R. Swanson, Nuclear Engineering Department Manager

The Honorable Edward J. Markey .

The Honorable Edward P. Kirby ,

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' The Honorable Peter V.'Forman

B. McIntyre, Chairman, Department of Public Utilities .

r Chairman, Plymouth Board of Selectmen i

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- Chairman, Outbury Board of Selectmen

Plymouth Civil Defense Director

P. Agnes, Assistant Secretary of Public Safety, Commonwealth of ,

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Massachusetts i

S. Pollard, Massachusetts Secretary of Energy Resources

R. Shimshak, MASSPIRG

PublicOccumentRoom(POR)  !

i Local Public Document Room (LPOR) l

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Nuclear Safety Information Center (NSIC) ,

l "RC Resident Inspector J

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Region I Docket Room (with concurrences) i

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R.Blough,DRP

L. Doerflein, DRP l

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R. 3orer. DRSS f

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0FFICJAL RECOR9 t@Y RL PILGU M 88-17 - 0002.0.0 )

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Rocky Hill Road

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Ptyrnoutn. Yassachusetts 0236o

June 25, 1988

le'Prident - Nuclear o W. M-M

U.S. Nuclear Regulatory Commission

Attn: Document Control Desk

Mashington, D.C. 20555

Dockei No. 50-293

Licento No. DPR-35

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Subject: NRC Insoectiop_Agpprt 50-293/88-17 (Rescortt).

Dear Sir:

Attached is Boston Edison Comp &ny's response to the NRC Region I Maintenance

Assessment Team Inspection conducted from April 25 through May 5, 1988, at the

Pilgrim Nuclear Power Station (9NPS), Plymouth, Massachusetts and at the l

Braintree, Massachusetts engineering office.

Boston Edison Company concurs with the NRC Assessment Team conclusions that:

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1. No violations of regulatory requirements were identified during the

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inspection.

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2. Several progra'.a and performance strengths werc identified.

3. Certain concerns, including some that were considered significant,  !

were identified. I

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These conclusions are consistent with the actions mandated by our Material )

Condition Improvement Action Plan (MCIAP) and the independent conclusions of '

our Restart Readiness Self-Assessment (RRSA) conducted between April 18, 1980 l

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and May 2, 1988. Boston Edison Company has accelerated the actions necessary

to implement those MCIAP and RRSA ite:ns which will resolve the significant NRC

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Assessment Team concerns.

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Boston Edison Company will address prior to restart, concerns identified in '

the areas of (1) maintenance program, (2) staffing, and (3) program

performance. The details and status of our corrective actions are discussed

in Attachment A. R. I.edgett and R. Blough agreed on 6/23/88 that sul;mittal of

this letter by 6/27/88 is acceptable. l

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.- Bost6n Edison Company Page 2

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Docket No. 50-293

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License No, DPR-35

Please do not hesitate to contact me if there are questions or comments

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regarding the attached response.

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RLC/b1

Attachment

cc: Mr. Hilliam Russell -

Regional Administrator, Region I

U.S. Nuclear Regulatory Comission

475 Allendale Rd.

King of Prussia, PA 19406

Sr. Resident Inspector - Pilgrim Station

Standard BECo Distribution

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. Boston Edison Company BECo Ltr: 88-98

Pilgrim Nuclear Power Station Docket No. 50-293

License No. DPR-35

Insoection Reoort 88-17 ResRQa51

Boston Edison has reviewed the concerns discussed in Section 1.2 of the NRC

Maintenance Assessment Team Report and concurs with the NRC Assessment Team

conclusions. These conclusions are consistent with the independent actions

and conclusions of our Material Condition Improvement Action Plan (HCIAP) and

our Restart Readiness Self-Assessment (RRSA) conducted during the period of

April 18, 1988 to May 2, 1988. Boston Edison has accelerated the

implementation of those MCIAP and RRSA actions necessary to resolve the

significant NRC Assessment Team concerns. The areas of concern are:

Maintenance Program

Maintenance Staffing

Program Performance

I. Maintenance Program

The following is a summary of the actions taken in the area of the Maintenance

Program:

Boston Edison has taken action to more clearly define work control

practices in approved plant and department procedures as well as to

formalize the current plant work control practices for Maintenance.

- To accomplish this, the ongoing comprehensive rewrite of the PNPS

Maintenance Section Manual was completed to more clearly describe its

purpose, intent, structure, and its relationship to other station

directives and procedures. This rewrite incorporates INPO Guidelines85-038, "Conduct of Maintenance at Nuclear Power Station", to enhance

maintenance practices at Pilgrim Station. Additicnally, Boston .

Edison performed a major rewrite of PNPS Procedure 1.5.3, '

"Maintenance Recuests", to incorporate improved administrative

controls. A new procedure, PNPS Procedure 1.5.3.1, "Haintenance Work '

Plan", was developed to be utilized in conjunction with the l

Haintenance Request (HR) as an administrative tool to provide a Hork '

Plan which further defines (details) the maintenance activity to be

performed.

Boston Edison has taken action to provide improved specifications for

unique and routine maintenance previously covered by Procedure 3.H.1-il,

"Routine Maintenance", to ensure adequate preparation of work packages for i

such tasks.

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. .' ATTACHMENT 'A'  ;

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Insoection Renort 88-17. Response

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- To accomplish this Boston Edison prepared, approved, and implemented

Procedure 1.5.3.1, "Maintenance Mork Plan". This procedure, used in

conjunction with the revisto Procedure 1.5.3, "Maintenance Requests",

provides an effective means to specify unique instructions for

routine maintenance tasks formerly covered by Procedure 3.M.1-11.

Maintenance Mork Plans are now required to contain specifically ,

defined steps for the performance and documentation of maintenance

activities. MRs written prior to the implementation of the revised

maintenance program, and which referenced Procedure 3.M.1-11, are

reviewed and approved by the Plant Maintenance Section Manager prior

to implementation to ensure that the intent of the revised

maintenance procedures is met. -

II. Maintenance Staffina

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Bosten Edison conducted a review in the last quarter of 1987 of the authorized

staffing level. An integral part of this review included an estimate of

manpower resources required to meet and maintain the established performance

goals of the Maintenance Section.

Based on this review, the permanent full-time Maintenance complement has been

increased. Ten of these positions are supervisory positions. Revisedjob

descriptions have been developed for this expanded organization and hiring

efforts are aggressively underway.

Attention to the plant's material condition has been increased by the

expansion of the permanent complement of niaintenan:e personnel. Attention has

been further enhanc.ed, by assignment of the Systems Engineering Division (SED)

to provide increased support to individual maintenance activities thereby

reducing the burden on maintenance personnel. The SED conducts in-depth

research for the majority of individual Failure and Halfunction Reports

(F&MRs).  ;

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The overall knowledge, experience, and performance levels of the Maintenance

staff is being improved. This is being accomplished by:

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Recruitment of personnel with greater experience levels to fill

vacant and new positions.

Improved training.

Development of well-defined job descriptior.s. ,

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Improved Maintenance management and supervision.

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The experience level of the Maintenanc.e staff has been further enhanced by .

creating the position of Deputy to the Maintenance Section Manager. This j

I,osition has been filled by an individual with approximately 25 years of i

experience in production and planning for nuclear repair, overhaul, and 1

refueling work.

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ATTACHMENT 'A'

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Insoection Recort 88-17 Resoonse

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III. Maintenance Performance

Boston Edison, through programmatic changes, is implementing actions which

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will increase attention to detail as well as improve familiarity with various

! elements of the werk co'ntrol process. The improvement in the mainteaance

program described in Section I above, in conjunction with the staffing '

increase and upgrades, is designed to result in improved maintenance

performance.

The following is a summary of the actions taken to improve performance:

Boston Edison has taken action to ensure that hrs are both complete and

correct.

- The revision of Procedure 1.5.3 incorporated additional guidance and

requirements regarding the preparation, review, and approval of hrs

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to ensure correctness and completeness. The Haintenance Summary

Control (MSC) form has been deleted. The function of the MSC has  ;

been integrated into the new Maintenance Work Plan (Procedure 1

1.5.3.1). Training has been conducted, with emphasis on the

appropriate method of processing a work plan and the need for the

documentation to be complete and accurate.

Boston Edison has taken action to control expansior or revision of the

original work scope during maintenance in the field and to require

documentation of the actual work performed.

- To accomplish this, Procedure 1.5.3.1 specifies the controls

necessary to make revisions to the work package. Additionally, any

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revision to the Work Plan must be reviewed and approved in the same i

manner as the original document. The work performed will be 1

documented and will become a part of the completed maintenance

package.

Boston Edison has taken action to ensure that complete work packages,

including necessary instructions, are available at the work site.

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The revised maintenance program now provides the necessary guidance

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and program controls to ensure that work packages, including the

necessary instructions, are available at the applicable work site

when maintenance activities are being performed.

Boston Edison has taken action to ensure that Maintenance provides

documentation of material used, maintenance and test equipment I

information, and work performed (including torque values).

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- The Work Plan now requires this information to be documented by the

maintenance personnel and becomes a part of the completed work l

. packa e. The process develops a chronological history of the i

indiv dual activities. l

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Boston Edison has taken action to improve storage and retention of

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maintenance records.

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ATTACHMENT 'A'

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, Insoection Reoort 88-17 Resstant

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- Upon completion of a maintenance task, the final work package is

returned to the responsible Staffing / Planning Engineer for review and

closure. It is then processed by Document Control for retention as a

complete package.

Boston Edison has taken action to ensure proper documentation of post work

testing.

- The Work Plan now requires the maintenance post work testing to be

identified, reviewed for adequacy, and results documented as part of

the completed work package. ,

These program improvements, coupled with the increased management focus and

direction, will ensure continued program improvement.

IV. 01erview of the Revised Maintenance Program

The comprehensive rewrite of the Maintenance Section Manual for PNPS is

complete. The changes and additions more clearly describe its purpose,

intent, structure, and its relationship to other station directives and

procedures. This rewrite incorporates INPO Guidelines85-038, Conduct of

M;intenance at Nuclear Power Stations, to enhance maintenance practices at

Pilvim Station.

Boston Edison also performed a major rewrite (revision) of PNPS Procedure

1.5.3 "Maintenance Request" (MR) to incorporate stronger administrative

controls to identify problems, initiate, plan, track and accomplish station

maintenance with precise supervisory control on both safety-related and

nonsafety-related components, equipment, or structures. A new procedure, PNPS

Procedure 1.5.3.1 "Maintenance Work Plan" (MHP), was developed to be utilized

in conjunction with the Maintenance Request as an administrative tool to

provide a Hork Plan which further defines (details) the work to be performed

including special tools, equipment, procedures, instructions, technical

documentation, expected exposure levels (if applicable) and to provide

feedback when work is completed. Revisions to MHPs will not change the intent

of the work scope originally approved. Revisions to the Work Plan will be

reviewed and approved in the same manner as the original document. The Work

Plan and the parent MR are the controlling documents for installation of a

modification or performance of a maintenance work activity. The Work Plan

specifies the requirements for examination, and testing, and includes the

applicable instructions, procedures and drawings. It also specifies

hold / witness points and provides for controlling the work in the event of a

nonconformance, i

The highlights of these major revisions to PNPS Maintenance procedures are:

(1) the work documents are incorporated into a single work package for each i

work activity, (2) the process of the Maintenance Work Package provides

increased control in that the engineer who develops the package maintains

control during the process, (3) Management level review and approval of

revisions, including Quality Control and Operations, are part of the process,

and (4) the final package, along with copies of the required documentation is

returned to the engineer for review, closure, and processing to Document '

Control. These procedure revisions have been completed, reviewed, approved

and implemented.

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Insoection Recort 88-17 Rt1RADit

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Boston Edison has conducted a series of formal training sessions for the '

Maintenance Managers, Supervisors, Maintenance Craft and selected personnel

from other sections that are directly or indirectly involved in the (

processing, review, or examination of the new MR/MHP process. This training i

was completed on June 17, 1988, with program implen,entation on June 20, 1980. t

) To reduce the impact on production, and provide a smoother transition,

management oversight of the new MR process is being increased during the

implementatlan phase. In addition, the Quality Assurance Surveillance ,

Division will be conducting surveillance on the revised Maintenance Program to '

i monitor implementation and performance. l

This response focuses primarily on the corrective actions taken to resolve the

concerns described in Section 1.2 of the Team Report, Other corrective

actions and program improvements have also been identified and are being

addressed by Boston Edison Management. Although some items are not designated

as RESTART actions, these items are incorporated into long term programs such

as the "Material Condition Improvement Action Plan" (MCIAP). Boston Edison is

continuing these actions / improvements with the goal of achieving and ,

sustaining the highest standards of maintenance performance.

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Pd9 sn h'uc! car Power station

Rocky H41 Mo4d

f rymouth, Massachusetts 02360

Ralph G. Die

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July 7,1988

U.S.1;uclear Pegulatory Commission BECo Ltr. #88-103

Attn: i

Document Control Desk

Hashington. D.C. 20555

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Docket No. 50-293

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Subject: 1.icense_No_DPR-35

Soool.emer,tal Rescoqse to NRC Insoection .

Bg;m 1 No. 50-293/88-11

Dear Sir:

Maintenante staffing and performance

NRC Inspection 88-17 dated 6/25/88

with respect to and suppleThe

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The information is submitted inments our iinitial res

a telephone conversation on July 1, 1988.accordance r. Highfill during

with an

Please do not hesitate to conta

regarding the attached response.ct me if there are questions or comments

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PJH/dmc

Attachmept

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cc:

Mr. William Russell

Regional Administrator, Region I

U.S. Nuclear Regulatory Commission

475 Allendale Rd.

King of Frussia, PA 19406

Sr. Resident Inspector - Pilgrim Station

Standard BECO Distribution

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Boston Edison Company BECo Ltr: 88-103

Pilgrim Nuclear Power Station Docket No. 50-293

License No. DPR-35

hpplemental Resoonse to NRC Inspection. Report No. 50-293/88-17 '

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The Haintenance organization, including supervisory and planning positions, is  !

fully staffed with a combination of Boston Edison and contractor personnel. '

An aggressive process is in place to hire permanent personnel for those l

positions currently fil'.ed by contractors. Current projections show permanent

positions will be filled with Boston Edison personnel by August 31, 1988. Our

plan is to maintain the Maintenance Organization fully staffea (i 5 positions)

utilizing contractors when necessary.

The existing Haintenance staff (both Boston Edison and contractors) is trained

on the recent changes that were made to enhance the work control process. New

personnel will be trained as appropriate on the process which is discussed in

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our initial response to Inspection 88-17.

To increase the attrartiveness of jobs in Haintenance, specific actions have

been taken:

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Physical working conditions have been improved as a result of the plant

decontamination program. Fewer jobs require the use of cumbersome

protective clothing to perform.

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Administrative workload on Haintenance supervisors has been reduced by

addition of the System Engineering Division and implementation of the

Haintenance Planning Division. Maintenance work controls have been

upgraded providing more specific guidance to the individuals performing

maintenance activities.

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Haintenance staff overtime has been reduced.

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The supervisor to craft ratio has been improved, t

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1.ong term action to upgrade supervisory training has been initiated.

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Specific perfor: nance goals in the Haintenance area have been established for

restart and operation. The goals are based on industry guidance and are .

published / posted routinely to keep personnel informed of progress towards the

goals.

P_er foLmanct 1

In response to the results of Inspection 88-17, several actions have been

taken to ensure adequacy of previously performed maintenance activities.

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JUL 08 '88 16 01 PILGRIM NRC RESIDENT P05

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EUDA).gmental Resom.e to NRC_Insoection Reonrt No. 50

3oston Edison Company has reviewed the concerns identified by the

Team regarding the sample

during the Haintenance Inspection. of Haintenance Requests spection

e team

(MR) revie

These concerns are currently being i

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activities by reviewing and compiling availabl

was performed by these hrs.

Where documentation was not available, walkdowns

were performed to ensure adequacy.

The documentation for one postTo datetest

work no could reworknot has

bebeen identified.

located

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To address

assessment of these concerns is expected to b .

The

The

Quality Control Divisions oversight of work on sa

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qualified maintenance staff at Pilgrim Station.Inna summary, a

program improvements are adequate. assessment indicate that mai

of historical maintenance records Our conclusion

and walkdowns is basedperformed on the assessmen to date

resulted

of previous in no rework,

activities. coupled with the Quality Assurance g

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